164 Part to be interpreted in accordance with OECD principles

Application of OECD principles

164  Part to be interpreted in accordance with OECD principles

(1)     This Part is to be read in such manner as best secures consistency between—

(a)     the effect given to sections 147(1)(a), (b) and (d) and (2) to (6), 148 and 151(2), and

(b)     the effect which, in accordance with the transfer pricing guidelines, is to be given, in cases where double taxation arrangements incorporate the whole or any part of the OECD model, to so much of the arrangements as does so.

(2)     Subsection (1) has effect

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